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Jodi MasQn-Whltlow,
Pial nt I ff
J N TilE COIIRT OF COMMON PLEAS OF
v,
CUMBERI.AND COUNTY, PENNSYLVAN I A
Reynold II, Whitlow, III,
Def end/In t
NO, 98...
(' I V I L 'I'EHM
PIWTi':('T 1 ON FHOM AIlUSE
ANIl CUSTODY
NOTlell
You have been Hued In court. lf you wish to de fond against the
cllllms sot forth In the following (lllges, you lIIust tllko action (lromptty
aftor this Potition, order Ilnd Notice Ill'e servlHl, byappellrlng
PI"'llollally or by IIttorney lit lhl' h{Jurlng ,.chcduled by the Court llnd
presenting to the Court your dcfcnscs or objections to the claims set
forth against you, You lire wllrned t.hllt if YllU fai I to do !IO the Court
may proceed without you, und II judgment mllY be entered against you by
the Court without further notice for Ilny money claimed in the PI,tition
or for /lny otll(!r claim 01' relief requested by the plaintiff, You may
lose money 01' property or olher rights Impllrtunl to you, A.ny
Protection Order granted by a Court may be considered in any
subsequtmt domeHtic f'ldatlons prrlCI){Hlings, including custody actions.
J~l':I~S ANU_...QQ~rS
If the cllse goes to hearing Ilnd the judge grants a Protection
Order, II surchlll'ge of $25,00 wi I t be Ilssessed against you, You may
Illso be rcquired to pay up to $250,00 to reimburse one of Legal
Services, Inc, 's funding sources for Leglll Services Inc, 's
representation of the plaintiff,
You have the right to be represented by counsel. You should take
this pupcr to your Iuwyt,r atllnce, If you do 1I0t have a lawyer' or
cannot afford one, go to or telephone the office set forth below to
find out where you can get legal help.
CUMBERLAND COUNTY liAR ASSOCIATION
2 UBERTY AVENUF:
CARLISLE, PENNSYLVANIA 1701.1
TELEPHONE NUMBER: (717) 249,-.1166 or TOLL FREE: 1-.800-990-9108
fAX: (717)249-2663
A..."lItRlGM!5..JHT!! .lHll.M!.!.L.!I1ES ....ACT_ O!':...l29.Q
The Court of ('omOlon Pll'as of CumblHtllnd County Is required by law
to comply with the Amcl'icllns wit.h Disabilities Act of 1990, For
lnfol'llllltlon id)(Iut Ilccessible file/titles and rellsollllble IIccommoclations
available to dlsllbled indivldullls hllving buslnoss before the court,
(dellse contllcl OUI' office. All ilJ'l'llngcments must be mude Ilt least 72
hours prior to lIn,V he/lrlng 01' business before the court:, Vou mUst
nttol1d th(, scheduled conferenee or hearing,
slllmmlld thl' front door locking tho plaintiff out of the
rosldtHlc{!, When thc plnlntlff cntered tho I'osldoncl'
wi th n spare k!,y, tll(' rlefcndnnt IHI.~hed her wi th his
chcst, HCl'lnlmod In tHlr fIlCl', nnd hit her with the back
of his hlllld bt'(,"king h,JI' nose In two plIlCl!S nnd cllusing
her to filii onto the floor, The defcndllllt covered the
plnlntiff's mouth with his h/lod refusing to Illlow her
to screllm for help nnd kicked her In the back nfter she
fell onto the fluor. The defendunt grabbed the
pJulntiff hy the hiliI', pulled her up the stairs by the
hail', IIn<l slummed her he/ld into the walt and the stairs
severlll times, As the plaintiff uttempte<l to escape
the residence, th<, defendant slnlllUlod the front door on
her wrist clluslng /I frtleture. As the plaintiff htdd
the part ies' minor son In her /ll'InS, the defendant
grabbed the plaintiff hy the bllck of the shirt ellusing
her to filii onto the floor, grllbbed her by the hall',
slammed her hClld against the wall several times, IIn<l
grabbed her by the throat choking her until she almost
lost consciousness, The plnlntlff flnnll.v escaped from
the residence and called the pol ice who IIrrested the
defendllnt,
b. On or about the Slimmer of 1995, the defendant
shovod the pl/tintiff onto the floor, grabbed her by the
neck, nnd threw her onto the sorn,
2
c. On several occlIsinns since the summer of 1995, tho
defendant hils lifllllshed telephones, thrown ohjects, and
punched holes in wal Is and doors with his fists causing
her to felll' for her lillfety,
5. On 01' about April 23, 1998, the defendant wus escorted
from the residence at 1703 English Drive, Mechunll'sburg,
Cumberland County, Pcnnsylvaniu, and was ordered to stay away
frr.m the residence as (l condition of his bull.
6. Tho plaintiff believes and therefore avers that she is
in immedillte and present danger of abuse from t he defendant
should she remain in the home without the defendant's exclusion
and that she is In need of protect ion from such IIbuse.
7. The plllintiff desires that the defendant be prohibited
from having finy direct 01' indirect contact with the plaintiff
including, but not limited to, telephone and written
communications, except for the limited purpose of facilitating
custody arrangements.
8. The pl/lint iff desi res that the defendant be enjoined
from harassing and statking the plaintiff, and from harassing the
plaintiff's relatives.
9. The plaintiff desires that the defendant be restrained
from entering her place of emptoyment,
10. The pl/lintiff desires thnt the defendant be enjoined
from damaging 01' destroying any property owned jointly ~y the
parties or owned solely by tho plaintiff.
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J!.........JIXGlJ15lYli . JlQ1UW!U1 ION
11. 'l'he hOllle from which the plaint iff is asking the Court
to exclude the defcndllnt Is rcnl(,d In th(, nllmeR of both the
plnint I rr and the dr.fendnnt.
12. The def(,ndant WIIS escorted from the ,'(\sldence at 1703
English Drive, Mechllnlcsburg, cumberland County, Pennsylvania,
and was ordered to stny aWIl)' from the resldlJlICll as a condition of
his bait. The c1efendllnt is currcntly rcsidlng wllh his mother at
225 Wesl Coover Slreet, Apllrlment 6-Rcllr, Mechllnicsburg,
Pennsy 1 vlln I a.
!2-._~..illIT
13. The defendant has a duty to supporl the plaintiff Ilnd
the minor child,
14, The plaintiff is in need of financial support from the
defendant Including, but not limiled 10: health insurance
coverage, payment of unl'eimbursed medical expenses for the
plaintiff and lhe chi Id, lhe rent pHYlllenl on the residence at
1703 English Drive, Mechanlcsburg, Cumbertand County,
pennsy I vlln I a.
15. The defendant Is employed at Chromai loy TAD, and has
nl1nuaJ slllary of $31,000,
16, The plninl iff current Iy has no income to provide for
her minimal needs afl(ilhose of the child until such time as a
support ord~r can be obtnlned by filing lit the Domestic Relations
Office.
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17. The plaintiff Intends to petition for support within
two weeks of the I ssullnce of II protectl ve order.
Q.,---.llltLMBUBl1EIo!I!NL..~:Q'i.G..QJ:LQ.t'. C,\U
18. The plaintiff lIsks thllt the defendant be ordered to PIIY
$250.00 to reimburse one of Legal Services, Inc. 's funding
sources for the cost of lltlgnting this ClIse.
-".....__I!t~)QRAB.L.G!1STOllY
19, The plll!ntiff seeks temporllry custody of the following
eh lid:
t!l!me
Ryan E. Whi t low
,P rlllln.L..R.!UUd e nj:e
1703 English Drive
Mechanicsburg, PA
h&~
1 year old
10/11/96
The chi Id was not born out of wedlock,
The child is presently in the cust.ody of the plaint.iff, Jodi
Mllson- Whi tlow, who resides at 1703 gngl ish Drive, Mechllnicsburg,
Pennsylvanin,
since his birt.h, the chi ld has res ided wi th the following
persons and nt the following addresses:
H.I!U AddLesses Dates
Plaintiff 1703 English Drive 4/23/98 to
Mechaicsburg, PA present
I'laintiff and 1703 English Drive 10/11/96 to
Defendant Mechaicsburg, PA 4/23/98
The plaintiff, the mother of the child, currently resides at
1703 English Drive, Mechanicsburg, Cumberland County,
pennsylvania,
She is mnrried,
.5
b, The defl<nclant has shown by his abuse of the
plaintiff that he is not an appropriate role model for
the IIIlnor child,
WIIEREFORE, pursuant to the provisions of the "Prot.ectlon
from Abuse Act" of October 7, 1976, 23 Pa,C,S, 9 6101 II .!ilLq" as
amended, the plaint.lff prays this Honorable Court to grant the
following re lief:
A. Orant a Te"~orary Order pursuant to the
"Proteotion frolll Abuse Act:"
1, OrderIng the defendant to refrain from
abusing the plaintiff or from placing her In fear
of abuse.
2. Ordering the defendant to refrain from having
any direct or lndlrect oontact with the plaintJff
including, but not I imlted to, telephone and
written communications, except to facilitate
custody arrangements.
3. Ordering the defendant to refrain from
harassing nncl stalking the plnlntlff and from
harassing the plaintiff's relatives,
4. Prohibiting the defendnnt from entering the
plaintiff's ptBce of employment.
5. Prohibiting the defendant from damaging or
destroying property jointly owned by the parties
or owned solely by the plaintiff.
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6. Grllntlng possosslon of the homo locllted lit
170J English "rive, Meehanicaburll Cunilier!and
County, Pl1nmlylvllnlu, to the pllllntlff to the
exclusion of the dofendunt pending u flnul order
III this Illlltter, except for the I imlted purpose of
trllnsfel'l'Jng vustody of till! Pllrtles' child.
7, Grllntlng tl11llporury custody of the minor child
to the plaintiff,
fl. Schedule II hellring in accordance with the provisions of
the "Protect Ion from Abuse Act," Ilnd, after such hear lng, enter
an order to be in effect for II period of one year!
1. Ordering the defendant to refrain from
abusing the ptaintiff or from placing her in fear
of abuse.
2. Ordering the defendllnt to refrain from having
any direct or indiroct contllet with tho plaintiff
InclUding, but not 1 imi ted to, telephone and
written communlcutlor,s, except to facilitate
custody arrangements.
3. Ordel"ing the defendllnt to refrain from
harassing IInd stulklng the plaintiff and from
IHlrassing the plllintlff's relatives.
4. Prohibiting the defendant from entering the
plaintiff's place of employment.
S. Prohihi t Ing the defendant frolll damaging or
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residence located at 1703 English Dtlve, Mechanicshurg,
Cumberland County, /lcnnsytvanla, and any other residence the
plaintiff may estabtish, except for the limited purpose of
transferring custody.
7. The defend/lnt Is ordercd to provide health coverage to
the plnintlff and minor child, and to make rent paymcnts for the
plaintiff's residence,
8. The court costs and fees are waived.
9. This Order shal t remain In effect for a period of one
year or until modified or terminated by the Court, The Order can
be extended beyond Its original expiration date if the Court
finds that the defendant has committed another net of abuse or
has engaged in a pattern or practice that indicates continued
risk of hnrm to the plaintiff.
10. A vlolatl()n of this Order may subject the defendant to:
I) arrest under 23 Pa.C.S. ~6113; il) a private criminal
complaint under 23 Pa.C,S. ~6113.1; III) a charge of indirect
criminal contempt under 23 /la.C.S. ~61l4, punishable by
Imprisonment up to six months and a fine of $100.00-$1,000.00;
and Iv) civil contempt under 23 /la.C.S. ~6114.1. Resumption of
co-residence on the part of the plaintiff and defendant shall not
nullify the provisions of the court order,
11, The Upper Atlen Township Police Department shall be
provided with a certified copy of this Order by the plaintiff's
attorney nnd may cnforce this Order by arrest for Indirect
5. The defendant agreos not to damage or destroy any
property owned by the plaintiff or jointly owned by the parties,
6. The defendant agrees to stuy away from the plaintiff's
residence located at 1703 English Drive, Mechanlcsburg,
Cumberland County, Pennsylvania, and uny other residence the
plaintiff may establish. except for the limited purpose of
transferring custody.
7. The defendant is ordered to provide health coverage to
the plaintiff and minor child. and to make rent payments for the
plaintiff's residence.
R. The defendant. although entering Into this Agreement,
does not admit the allegations made in the Petition.
9. The defendant understands that the Protection Order
entered in this matter will be in effect for a period of one year
and can be extended beyond its original expiration date If the
Court finds that the defendant has committed another act of abuse
or has engaged In a pattern or practice that Indicates continued
risk of harm to the plaintiff. The defendant understands that
this Order will be enforceable in the same manner as the Court's
prior Temporary Protection order entered In this case.
10. Violation of the Protection order may subject the
defendant to: il arrest under 23 Pa.C,S. Y61t3; ill a pr1vate
criminal complaint under 23 Pa.C.S. ft61IJ.I; iii) a charge of
Indirect criminal contempt under 23 Pu,c,s, 16114, punishable by
Imprisonment up to six months and a fine of $100,00-$1,000,00;
and Iv) civil contempt under 23 PIl,C,S, 66114,1.
11. 'rhe defendllnt Ilnd the plaintiff agree to the entry of
an Order providing for the following regarding custody of their
child, Ryan E, Whitlow (DOB 10/11/96),
a, The mother Ilnd father shall share legl.\l custody of
the child,
b, The mother shllll have primary physical of the
child.
c. The father shall have part illl custody of the chi Id
at times agreed upon by t he mot her /lnd fllther,
d, The mother and falher /lgree that each shall notify
the other ImmedJlltely of medical emergencies which
arise while the child Is In that parent's care.
e. The mother and father realize that their child's
well being is paramount to any differences they might
have between the01selvtls. Therefore, they agree that
neither party shllll do anything which mllY estrange the
child from the other (Jarent, or Injure the opinion of
the chi Id as to the other purent or which mllY hamper
the free Ilod natural development of the child's love or
respect for the other pllrent,
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